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Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Commercial Debt Obligation Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(1)- Commercial Debt Obligation Whether forgiven amount arises on settlement of contractual claims (pp. 13:34-13:35) In addition to the issue of deductibility of claims for contractual damages, consideration must also be given to whether the settlement of any such claims under a restructuring for less than the amount of the liability may result in the application of the debt forgiveness rules.... ...

Angelo Nikolakakis, Alain Léonard, "The Acquisition of Canadian Corporations by Non-Residents: Canadian Income Tax Considerations Affecting Acquisition Strategies and Structure, Financing Issues, and Repatriation of Profits", 2005 Conference Report, c. 21, p. 21:8.-- summary under Subsection 212.1(4) Summary Under Tax Topics- Income Tax Act- Section 212.1- Subsection 212.1(4) In step 1 of figure 4, Bidder transfers Target to Bidder Forco in exchange for a promissory note ("the Bidder Forco reorganization note") with a face amount equal to the fair market value (FMV) of Target. ... It should also be possible for Target subsequently to be combined with Bidder Canco, although additional considerations will arise, including with respect to capital tax liability concerns (see the discussion below). ...

Robert Demers, "Indirect Tax considerations in M&A Due Diligence", 2015 CTF Annual Conference paper-- summary under Subsection 296(2.1) Summary Under Tax Topics- Excise Tax Act- Section 296- Subsection 296(2.1) GST erroneously paid on a volume rebate is not tax paid in error so that a credit therefor on assessment is not available Automatic application of unclaimed rebate for tax paid in error (p. 20: 19) If a rebate has not been claimed, the tax authorities must apply the unclaimed rebate against the net tax assessed when preparing an assessment. ... An example would be a case where tax is paid in excess of an amount that does not constitute the consideration for a supply, or where the tax is paid over and above a volume discount whereas no tax was collected on the original supply. ...

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper-- summary under Subsection 80(13) Summary Under Tax Topics- Income Tax Act- Section 80- Subsection 80(13) Requirement to use related person’s tax attributes on s. 80.04 designation (p. 13:9) Further considerations arise when a debtor seeks to make a designation of the forgiven amount in respect of the shares or debts of the related corporation or interests in related partnerships (i.e. the third category of capital property referenced above [in s.80(11)]. ...

Brown, Newton, "Tax Considerations in the Design of a Flexible Benefits Plan", Taxation of Executive Compensation and Retirement, Vol. 7, No. 2, September 1995, p. 22.-- summary under Paragraph 6(1)(a) Summary Under Tax Topics- Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) ...

Schwartz, "Statutory Amalgamations, Arrangements and Continuations: Tax and Corporate Law Considerations", 1991 Conference Report, c. 9.-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) ...

Schwartz, "Statutory Amalgamations, Arrangements and Continuations: Tax and Corporate Law Considerations", 1991 Conference Report, c. 9.-- summary under Subsection 87(9) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(9) ...

Vesely, "Takeover Bids: Selected Tax, Corporate and Securities Law Considerations", 1991 Conference Report, c. 11.-- summary under Subsection 85(1.1) Summary Under Tax Topics- Income Tax Act- Section 85- Subsection 85(1.1) ...

Vesely, "Takeover Bids: Selected Tax, Corporate and Securities Law Considerations", 1991 Conference Report, c. 11.-- summary under Subsection 87(1) Summary Under Tax Topics- Income Tax Act- Section 87- Subsection 87(1) ...

Smith, "Corporate Restructuring Issues: Public Corporations", 1990 Corporate Management Tax Conference Report, pp. 6:8-6:10: discussion of receipt of non-share consideration.-- summary under Subsection 85.1(1) Summary Under Tax Topics- Income Tax Act- Section 85.1- Subsection 85.1(1) ...